1. Acquisition tax imposed by the Defendant on the Plaintiff on January 13, 2014, KRW 85,801,800, local education tax, KRW 7,960,180, and special rural development tax.

1. Details of the disposition;

A. On March 8, 2011, the Plaintiff acquired securitization assets in KRW 128.2 billion from the Industrial Bank of Korea to a special purpose company established under the Asset-Backed Securitization Act, as well as from the Industrial Bank of Korea on March 29, 2011, securitization assets including loan claims secured by 2-385, Dong-dong, Dong-gu, Incheon and its ground buildings (hereinafter “instant real estate”).

B. In order to recover the above loan claims, the Plaintiff directly participated in the auction procedure on the instant real estate, and won the instant real estate at the auction on March 7, 2012, and paid in full.

C. As to the acquisition of the instant real estate, the Plaintiff reported and paid the acquisition tax, local education tax, and special rural development tax to the Defendant, the tax amount of 50/100 of which was reduced or exempted pursuant to Article 120(1)9 of the former Restriction of Special Taxation Act (amended by Act No. 11614, Jan. 1, 2013; hereinafter the same).

On January 13, 2014, the Defendant: (a) deemed that the acquisition of the instant real estate does not fall under those subject to reduction or exemption of acquisition tax under the former Restriction of Special Taxation Act; and (b) rendered a disposition imposing acquisition tax of KRW 85,801,80, and local education tax of KRW 7,960,180 (total amount of KRW 97,432,070) on the Plaintiff (hereinafter “instant disposition”).

[Ground of recognition] Facts without dispute, Gap evidence 1, Eul evidence 1 to 4 (including branch numbers; hereinafter the same shall apply) and the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s tax notice of the instant disposition (hereinafter “instant tax notice”) cannot be identified as well as the individual tax base and tax amount of the land and building among the instant real estate, and the local education tax, special rural development tax, and the tax rate of each item are not indicated, and the principal tax and additional tax cannot be identified separately.

In addition, the pre-announcement of taxation prior to the disposition of this case is also difficult to identify the individual tax base and amount of tax of land and building among the real estate of this case, as well as the applicable laws